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procure sham criminal charges against Chevron's attorneys. Three, conduct a massive public
pressure campaign designed to spread false and misleading information about Chevron and the
Lago Agrio Litigation. These lines of attack are related but nonetheless distinct attempts to
pressure Chevron into paying the RICO Defendants. Donziger has even admitted that the
criminal charges and the pressure campaign were not simply means of supporting the Lago Agrio
Litigation, but "other things in play outside of the legal case." The ultimate objective, in
Donziger's words, is to cause "damage to [Chevron's] reputation," to put "personal
psychological pressure [on] their top executives" through threats and attacks through the media
and force Chevron into a payoff
70. Donziger has explained how the conspirators work to increase costs for Chevron
on all fronts until it gives in to their extortionate demands:
The work doesn't let upjust because I'm in the U.S., at all. [mean, it's still really
intense, you know, so it's always looking for ways to increase the leverage and
increase the cost to Chevron for not doing anything. So, what's the cost? The
cost is, right now, it's the cost of the risk of getting a huge multi-billion dollar
judgment at trial, ... it's the cost of all the hassle they have to put up with from
the environmental groups, ... it's the cost of their sullied reputation, you know, in
the media.
71. The RICO Defendants and their co-conspirators have shown no signs of
stopping their attack. Indeed, Donziger has threatened to try to enforce the fraudulent judgment
obtained in the Lago Agrio Litigation in the United States and in other foreign jurisdictions,
observing that "Chevron operates in more than 100 countries and has numerous oil tankers that
troll the world's waterways and dock in any number of ports .... " In a recent speech, Donziger
asserted that the conspirators are assembling a legal team to "seize assets, seize boats," wherever
Chevron's subsidiaries operate around the world-even though the Lago Agrio Plaintiffs
previously told this Court that Chevron's defense against any Lago Agrio judgment should be
restricted to New York's recognition act. Fajardo has likewise warned that the RICO Defendants
plan to confiscate Chevron's assets in the United States in order to enforce the judgment. And
Donziger has also stated that the conspirators' plan is to move on from Chevron and Ecuador and
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